As Imperial Tobacco Turkey, we demonstrate utmost sensitivity regarding the security of your personal data. With this awareness, as a Company, we attach great importance to processing and preserving all types of personal data belonging to all individuals related to the Company in accordance with the Personal Data Protection Law No. 6698 (“PDPL”).

With full awareness of this responsibility, Imperial Tobacco Turkey, as the “Data Controller” defined under the PDPL, processes your personal data as explained below and within the limits mandated by legislation.

In this disclosure text:

Personal Data: refers to all types of information relating to an identified or identifiable natural person,

Personal Data Protection Law (“PDPL”): refers to the Personal Data Protection Law No. 6698, which was published in the Official Gazette on 07.04.2016 and entered into force,

Data Controller: refers to the natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system,

Data Processor: refers to the natural or legal person who processes personal data on behalf of the Data Controller based on the authority granted by the Data Controller.

Data Controller:

Your personal data shared with the capacities of counterpart, supplier, customer, employee, intern, visitor, etc. in accordance with the PDPL will be evaluated by Imperial Tobacco Turkey legal entity, determined as the data controller, within the scope specified below.

1. Collection, Processing and Operating Purposes of Personal Data

Your personal data may vary depending on your relationship with our Company; it may be collected verbally, in writing or electronically through automatic or non-automatic methods, through our Company units, website, social media channels, mobile applications and similar means. Your personal data may be created and processed by updating as long as your relationship with our Company continues.

Your collected personal data will be processed in accordance with the personal data processing conditions and purposes specified in Articles 5 and 6 of the PDPL for the purposes of carrying out necessary work by relevant business units for you to benefit from our Company’s services, ensuring the legal and commercial security of our Company and persons in business relationship with our Company, determining and implementing our Company’s strategies, and ensuring the execution of our Company’s human resources policies,

In compliance with law and honesty rules,

Accurate and current when necessary,

For specific, clear and legitimate purposes,

Limited and proportionate in connection with the purpose for which they are processed,

Preserved for the period provided for in relevant legislation or necessary for the purpose for which they are processed,

in accordance with the rules.

2. To Whom and For What Purpose Processed Personal Data May Be Transferred:

Your collected personal data may be transferred to our business partners, suppliers, legally authorized public institutions and private persons within the framework of personal data processing conditions and purposes specified in Articles 8 and 9 of the PDPL for the purposes of carrying out necessary work by relevant business units for you to benefit from our Company’s services, ensuring the legal and commercial security of our Company and persons in business relationship with our Company, determining and implementing our Company’s commercial and business strategies, and ensuring the execution of our Company’s human resources policies.

3. Method and Legal Basis of Personal Data Collection:

Your personal data is obtained in all kinds of verbal, written or electronic environments for the purpose of providing our services in line with the purposes stated above and in this context, enabling our Company to fulfill its contractual and legal responsibilities completely and accurately. Personal data collected for this legal reason may also be processed and transferred for the purposes specified in articles (1) and (2) of this text within the scope of personal data processing conditions and purposes specified in Articles 5 and 6 of the PDPL.

4. Rights of Personal Data Subject Listed in Article 11 of the PDPL:

As personal data subjects, when you convey your requests regarding your rights to our Company through the methods regulated below, our Company will conclude them free of charge within 30 days at the latest according to the nature of the request. However, if a fee is stipulated by the Personal Data Protection Board, the fee in the tariff determined by our Company will be charged. In this context, personal data subjects have the right to:

a- Learn whether personal data is processed,

b- Request information about this if personal data has been processed,

c- Learn the purpose of processing personal data and whether they are used in accordance with their purpose,

d- Know the third parties to whom personal data is transferred domestically and abroad,

e- Request correction if personal data has been processed incompletely or incorrectly,

f- Request deletion or destruction of personal data within the framework of conditions stipulated in Article 7 of the PDPL,

g- Request notification of operations performed in accordance with items (e) and (f) to third parties to whom personal data has been transferred,

h- Object to the emergence of a result against the person solely through analysis of processed data by automatic systems,

i- Request compensation for damages in case of suffering damage due to unlawful processing of personal data.

In accordance with the 1st Paragraph of Article 13 of the PDPL, you may convey your request regarding the exercise of your rights stated above to our Company in writing or through other methods determined by the Personal Data Protection Board. Since the Personal Data Protection Board has not determined any method at this stage, your application must be conveyed to our Company in writing in accordance with the PDPL. In this framework, the channels and procedures through which you will convey your written applications to our Company within the scope of Article 11 of the PDPL are explained below.

To exercise your rights stated above and your request containing the necessary information to identify your identity and explanations regarding the right you wish to exercise among the rights specified in Article 11 of the PDPL, you must deliver it clearly and comprehensibly, including documents that identify your identity and address information, in writing and with wet signature, by hand, by mail or through notary to kvkk@tr.imptob.com or to the address Keçiliköy OSB Mahallesi Ahmet Tütüncüoğlu Caddesi No:11 MOSB 3.Kısım Yunusemre / Manisa.

Respectfully,

Imperial Tobacco Turkey